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Anti-bribery policy template

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Our Anti-Bribery Policy template ensures clear guidelines, safeguarding against corruption risks and upholding ethical business practices.

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What is an Anti-bribery policy?

An Anti-Bribery Policy is a fundamental document outlining an organisation's commitment to preventing bribery and corrupt practices in its operations. This policy establishes clear guidelines and procedures to ensure compliance with anti-bribery laws and regulations. It defines acceptable and unacceptable conduct, providing guidance on interactions with clients, partners, and public officials to avoid bribery risks and uphold ethical business practices.

This policy sets the tone for a zero-tolerance approach towards bribery, outlining the responsibilities of employees, management, and stakeholders in identifying and preventing bribery-related activities. It often includes procedures for reporting suspicious behavior, receiving gifts, and engaging with third parties, establishing a framework that promotes transparency and accountability across the organisation. By outlining these standards, the policy safeguards the organisation's reputation, integrity, and legal standing while fostering a culture of ethical conduct among its members.

Implementing an Anti-Bribery Policy is crucial for organisations to maintain trust, credibility, and compliance within their operations. By clearly defining expectations and consequences, this policy helps mitigate the risk of bribery, protecting the organisation from legal ramifications and reputational damage. It serves as a pivotal tool in promoting a culture of integrity and ethical behaviour, ensuring that all stakeholders uphold high standards of conduct in their business dealings.

Anti-bribery policy template
anti-bribery policy template

What legal and best practice aspects should employers be aware of?

  • The Bribery Act 2010: The primary legislation outlining offenses relating to bribery and setting out strict liability corporate offenses for failing to prevent bribery.

  • Public Bodies Corrupt Practices Act 1889 and Prevention of Corruption Act 1906: Legislation pre-dating the Bribery Act, relevant for public bodies, addressing corruption offenses.

  • Criminal Finances Act 2017: Contains offenses related to corporate failure to prevent facilitation of tax evasion, which might be considered under anti-bribery policies.

  • Common Law Offenses: Historically, common law offenses like misconduct in public office are relevant to bribery-related matters.

  • Company Law: Directors' duties and corporate governance obligations may be considered concerning anti-bribery policies to ensure corporate compliance.

Anti-bribery Policy


Introduction

[Company] is dedicated to conducting business with the utmost integrity and in compliance with all applicable anti-bribery laws and regulations in England and Wales. This Anti-Bribery Policy outlines the principles and guidelines that all employees, contractors, agents, and representatives must adhere to when conducting business on behalf of [Company].

Scope

This policy applies to anyone acting for or on behalf of [Company]. This includes not only employees but for example contractors, agents and representatives.

General principles

Prohibition of Bribery

[Company] strictly prohibits any form of bribery, including offering, promising, giving, accepting, or soliciting bribes, whether in cash, gifts, hospitality, or any other valuable consideration, to gain an improper advantage.

This policy applies to all business dealings, whether with public officials, private entities, clients, suppliers, partners, or any other individuals or organisations.

Compliance with Laws

All employees must comply with the anti-bribery laws and regulations of England and Wales. This includes but is not limited to the UK Bribery Act, which came into force on July 1, 2011, and other relevant national and international laws.

Failure to comply with these laws and this policy can lead to severe legal consequences, including criminal charges, fines, and damage to [Your Company Name]'s reputation.

Facilitation Payments

[Company] strictly prohibits facilitation payments, which are small bribes intended to expedite routine actions or processes.

Employees must not offer or accept facilitation payments under any circumstances, as they are equally considered acts of bribery.

Gifts, Hospitality, and Expenses

Offering or accepting gifts, hospitality, or expenses in the course of business must be done with transparency and in accordance with the company's Gifts and Hospitality Policy.

Employees must not offer or accept gifts, hospitality, or expenses that could be perceived as influencing business decisions or creating obligations.

Due Diligence

Prior to engaging with third parties, such as suppliers, agents, or business partners, employees must conduct appropriate due diligence to ensure they have a reputation for integrity and compliance with anti-bribery laws.

Reporting and Whistleblowing

All employees have a responsibility to report any actual or suspected violations of this policy or any unethical behaviour through the company's established reporting channels.

Whistleblowers will be protected from retaliation, and reports will be treated with confidentiality to the extent allowed by law.

Training and Awareness

[Company] will provide regular anti-bribery training and awareness programs to ensure employees understand the policy's provisions and their responsibilities.

All new employees will receive training on this policy as part of their onboarding process.

Review and Update

This Anti-Bribery Policy will be reviewed periodically to ensure its relevance and effectiveness in combating bribery.

Updates will be communicated to all relevant stakeholders, and employees will be required to reaffirm their commitment to the policy.

By adhering to this Anti-Bribery Policy, we collectively safeguard [Company]'s reputation and maintain our commitment to conducting business with integrity and in the best interests of our customers and stakeholders.

This policy [does not] form[s] part of your terms and conditions of employment.

Version: [1.0]

Issue date: [date]

Author: [name, job title]

Direction

The Anti-bribery policy template is issued by an employer
Employer
Issue path
The Anti-bribery policy template is issued to an employee
Employee

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